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Banking Sector › Regulatory Requirements › Customer Identification Program (CIP)

Orrick, Herrington & Sutcliffe LLP

FDIC Approves Use of Pre-Populated Customer Information During Account Opening

Orrick, Herrington & Sutcliffe LLP on

On August 5, the FDIC announced that banks it supervises can comply with Bank Secrecy Act (BSA) requirements to obtain identity information from new customers by using a pre-populated form, provided that the person opening...more

Bradley Arant Boult Cummings LLP

How Banks Can Harness New Customer ID Rule's Flexibility

Bradley Arant Boult Cummings LLP on

Financial institutions across the U.S. have grappled with compliance requirements under the Customer Identification Program, or CIP, rule for more than two decades. On June 27, the Federal Deposit Insurance Corp., the...more

Husch Blackwell LLP

New Exemption Order Creates More Flexibility and More Considerations with the Customer Identification Program Rule

Husch Blackwell LLP on

By an exemption order dated June 27, 2025, federal prudential regulators have given banks and credit unions some welcomed flexibility when collecting an individual’s or entity’s taxpayer identification number (TIN) during...more

Skadden, Arps, Slate, Meagher & Flom LLP

FinCEN Seeks To Expand Reach of the BSA and Modernize Customer Identification Regulations

Skadden, Arps, Slate, Meagher & Flom LLP on

The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has recently taken steps to expand the reach of the Bank Secrecy Act (BSA) and related customer identification regulations. These steps build on...more

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